Management Response and Action Plan: Audit of Occupational Health and Safety at Health Canada and the Public Health Agency of Canada

Recommendation 1

The Assistant Deputy Minister (ADM) of the Corporate Services Branch (CSB) should ensure that the roles and responsibilities of occupational health and safety (OHS) oversight bodies are clear, documented, and communicated to ensure alignment with legislative requirements and promote standardization across Health Canada (HC) and the Public Health Agency of Canada (PHAC).

Management agrees with this recommendation.

• 1. The Occupational Health and Safety Management System (OHSMS) oversight roles and responsibilities will be reviewed, strengthened, and communicated as per legislative requirements.

• 1.1 A task force will develop a responsible, accountable, consulted, and informed (RACI) matrix to clarify the roles and responsibilities of the appropriate stakeholders for each OHSMS component.
• 1.2 The DM and the President will endorse the guidelines for the OHS Policies and Roles and Responsibilities.
• 1.3 The mandatory OHS e-learning module for all HC and PHAC employees will include a specific OHSMS Roles and Responsibilities section.
• 1.4 A communication and engagement strategy will be implemented regarding the OHSMS' roles and responsibilities for HC and PHAC senior management and all employees.

• January 2025

Recommendation 2

The ADM of CSB should establish a formal process to review the HC and PHAC OHS policies and regularly update them.

Management agrees with this recommendation.

• 2. A triennial review plan of the HC and PHAC OHSMS elements will be developed in collaboration with the OHS Policy Committees, as per the Standard CAN-CSA Z1000-14 OHSM.

• 2.1 The HC and PHAC OHS Policy Committees, the Deputy Minister (DM), and the President will endorse the OHSMS triennial review plan (2024-2027).
• 2.2 A communication and engagement strategy regarding the OHSMS's triennial review plan for 2024 to 2027 will be implemented for HC and PHAC senior management.
• 2.3 The OHS Policy Committees, the DM, and the President will receive a bi-annual report on the update of the triennial review plan.

• March 2025

Recommendation 3

The ADM of CSB should establish a process to ensure that mandatory training is reviewed and updated regularly, and that training is promoted, tracked, and enforced as required by the Canada Labour Code.

Management agrees with this recommendation.

• 3. As part of the OHSMS's triennial review plan, the mandatory training for HC and PHAC employees, Work Place Health and Safety Committees or Health and Safety Representatives, and OHS Policy Committees will be reviewed, updated, monitored, and promoted.

• 3.1 The OHS Training Standard will be endorsed and promoted.
• 3.2 The DM and President will endorse the OHS Mandatory Learning Path for HC and PHAC employees as part of the Performance Management Cycle.
• 3.3 A communication and engagement strategy regarding legislative requirements for completing the OHS Mandatory Learning Path will be implemented, including quarterly reporting to HC and PHAC EC.
• 3.4 A senior management accountability and compliance strategy to support the completion of the OHS Mandatory Learning Path through Branch Head Quarterly compliance reports will be developed and implemented.

• 3.1 January 2025
• 3.2 January 2025
• 3.3 January 2025
• 3.4 June 2025

Recommendation 4

The ADM of CSB should implement a robust monitoring system to track compliance with legal requirements on monthly inspections and emergency preparedness measures.

Management agrees with this recommendation.

• 4. A compliance monitoring strategy will be implemented ensuring HC and PHAC compliance with legislative requirements.

A human-centered integrated platform to maximize the health and safety of HC and PHAC employees, minimize reporting complexity, and streamline the OHSMS will be implemented, ensuring HC and PHAC compliance with legislative requirements.

• 4.1 An interim compliance monitoring strategy, such as MS Forms Compliance Surveys or others, will be implemented to ensure HC and PHAC comply with legislative requirements, including inspection and emergency preparedness measures.
• 4.2 An Integrated OHS Platform engaging OHSMS users will be developed and implemented to ensure that HC and PHAC comply with legislative requirements, including inspection and emergency preparedness measures.

• 4.1 March 2025
• 4.2 September2026

Recommendation 5

The ADM of CSB should implement standardized emergency preparedness training and drill exercises for employees across facilities in accordance with the TB Directive on Building Emergency and Evacuation Teams.

Management agrees with this recommendation.

• 5. The Building Emergency and Evacuation Program (BEEP) will be developed and implemented in accordance with the TBS Directive on Building Emergency and Evacuation Teams.

• 5.1 The OHS Policy Committees, DM, and President will endorse the BEEP before it is implemented in all HC and PHAC workplaces.
• 5.2 As part of mandatory onboarding training, a standardized emergency preparedness training will be developed for all employees.
• 5.3 A communication and engagement strategy on the BEEP will be implemented.

• 5.1 January 2025
• 5.2 March 2025
• 5.3 January 2025

Recommendation 6

The ADM of CSB should review processes on emergency preparedness to assess their effectiveness in the new hybrid work place reality.

Management agrees with this recommendation.

• 6. The Building Emergency and Evacuation Program (BEEP) will be developed and implemented in accordance with the TBS Directive on Building Emergency and Evacuation Team and will be adapted to the new hybrid work context.

• 6.1 A compliance monitoring strategy will be completed to assess the effectiveness of the BEEP in a hybrid work environment.

• September 2025